I really hope that the debate over chemicals can become a good-faith debate and not a spin debate. To find one-sided sets of arguments from all kinds of places always tracing back to the same sources is discouraging.
Yes, they looked at blood, because you can't take a human body and cook out all the fat. Blood is the best. You can take a fat incision; you can do all kinds of medical procedures. That's why they looked at blood, but we know these are fat-loving content and we know the body burden exists in fat. I consider that to be just the manufacture of confusion to people who don't know this.
On the question of the dose response on dioxin, I remember that in the early 1990s there was a big conference. The industry then put out big press releases saying that this conference concluded the dose response was near zero, that it was not toxic; then, in Scientific American, all the scientific associations said those were not the conclusions, that was just a public relations spin on the conclusions.
Originally the U.S. EPA was going to reassess its dioxin based on those findings. Now it's been 15 years, and because they couldn't make that case, they haven't ever concluded that reassessment and have reached no conclusions, because either you'll reach the right conclusion or there's enough money and enough influence to keep you from reaching any conclusion.
Hormesis, though, is different. There's a dioxin curve. I only said “linear” in the vicinity of zero. The dioxin curve is not linear. In very small quantities it has profound impacts, but as those quantities go up--that's what Seveso and other things say, and this poisoning in Ukraine--when populations, whether people or animals, are exposed to small amounts, it disrupts a lot of the basic biochemistry, and particularly affects development.
We have studies on PCBs in the Great Lakes of children whose mothers ate Great Lakes fish. These are old studies now. Their children had substantial learning deficits relative to mothers who didn't eat Great Lakes fish. We knew this a long time ago, but the scientists who found that in studies eventually were intimidated, and all kinds of other things happened.
I think the discussion should be a discussion in good faith, in that we are really trying to not just look for all of the partial scientific factoids that support one particular case.
Chemical regulation is a complicated matter. I think it's very fortunate that CEPA is reviewed every five years; that allows a possibility of updating maybe every eight or nine or ten years. New things are found out. I think that CEPA is finally--and in your last review--starting to take up these chemicals for which there are very little data. I forget the name of the list, but you have a list of 23,000 chemicals that were originally grandfathered in, and you've now characterized them. I think that's a very important step. The question now is what's going to come next.
We think the European Union is moving in a good direction. They're actually starting to require the development of data on all these chemicals in more detail. Then they can move into regulatory decisions on them. If I understand, I believe your inherent toxicity criteria are still based on how many fish will die--the lethal dose 50--and do not take into account many of the other toxicological approaches.
Chemicals policy in a world where the environment of life is full of anthropogenic substances that are different from the chemical composition of life when things evolved is a very important responsibility on all of you. I believe that you need very sensitive legislation that goes for increased data and applies the precautionary principle--that is, a no-risk principle--but that also includes another principle that's different from the precautionary principle and that is also discussed and included in law in some places, a principle called the substitution principle. That is, if you have a substance, and it has hazardous properties that are well known but there are alternatives that do not have those hazardous properties or have less hazardous properties, if the economics and the utility are sufficiently compelling, there is sufficient reason to require substitution. You don't need to ban a chemical.
The final thing is, it's not the case that all chemicals can be safely managed. There are some chemicals that, if you produce them and they use them, end in the environment, particularly if they go into products, and so forth.
I very much hope you take a very close look at CEPA and continue to update it as the global debate on chemicals policy moves forward.